Legal Opinion
James L. Rose and Judy S. Rose v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 27, 1989No. 88-1012PublishedCited by 177 opinions
1Opinion of the Court
BOYCE F. MARTIN, Jr., Circuit Judge.
James L. and Judy S. Rose, the taxpayers, appeal from the tax court’s determination, 88 T.C. 386 (1987). The tax court found that their purchase of “reproduction masters” of Picasso originals from Jackie Fine Arts lacked economic substance apart from anticipated tax benefits. It also concluded that the taxpayers were not entitled to depreciation or miscellaneous deductions or investment tax credits on the property acquired and, in addition, they were liable for additional interest under § 6621(d) 1 which provides for interest on substantial underpayments…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Rose v. CommissionerUnited States Tax Court · 1987
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
4 more not listed; retrieve them via the Exa API.
3Cited by177 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- McCrary v. CommissionerUnited States Tax Court · 1989
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
172 more not listed; retrieve them via the Exa API.